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com CPSIA and Vintage Books Background The CPSC granted some relief from the onus of the CPSIA to publishers, booksellers, schools, libraries, literacy groups and others when it granted a stay of enforcement for “ordinary children’s books” printed after 1985. Additional relief was given to collectors by further exempting books too old or valuable to be used by children. Nonetheless, these guidelines leave many books unnecessarily classified as probable “banned hazardous waste” which imperils businesses, institutions, and of course, children. Vintage Books Are Safe • There are no cases ever of books contributing to a case of lead poisoning. • The CDC ranks books a 0.5 on a 1 to 10 scale of risk for lead poisoning • Book ink does not rub off on hands, lead cannot be leached from the ink by hand oils or saliva. Only ingestion leads to possible absorption. Eating books is rare and usually occurs only when a child has pica, a medical condition. • Preliminary testing from CPSC found only a few books in the 300 ppm range; Half Price Books testing of a random sample of 44 books published between 1970 and 1985 found none. • High exposure to children’s books is correlated with good outcomes on the variables associated with lead poisoning (such as school achievement, ADHD, learning disabilities, antisocial and aggressive behavior. Similarly, groups with the lowest exposure to books typically fare worst on these variables. (You’d expect the reverse correlation if lead in books were a problem.) • The CDC recommends a mentally stimulating environment for children at risk of or suffering from lead poisoning because both human and animal studies have shown an enriched environment can prevent and treat low to moderate lead poisoning; books are an inexpensive, effective way to stimulate children’s brains. A Continued Ban on Older Books Harms Businesses, Institutions and Children • There are tens of millions to hundreds of millions of vintage books still in circulation and use by children. • Emily Sheketoff, president of the American Library Association, estimates there are tens of millions of vintage books on the shelves of libraries alone. Schools and childcare facilities also have many older books in their libraries and classroom collections. Literacy programs also use many older books. • Millions of books printed after 1985 will also be lost, as many publishers did not provide print dates, only copyright or publication dates on books. • Used booksellers are suffering tremendously. One seller lost half her stock on Feb. 10th; another tossed $4000 of inventory; Half Price Books has removed thousands of books to warehouses. There are probably thousands of small used booksellers that have been affected.
Most vintage books are not in print in any form. Many titles with historic and artistic merit will be lost, as well as many books loved and needed by children. There is little chance of most of these books being reprinted or even preserved electronically. Social scientists also oppose the loss of these books which are frequently used as measures of societal attitudes, values, trends, etc. The collectible exemption is of little help, since the vast majority of vintage books are not valuable collectibles, but “readers’ copies” which typically cost less than new versions of the books. The loss of many millions of copies of useful books will harm all children, but it will harm those at the lowest end of society the most. These are also the children at greatest risk of lead poisoning – and books can help offset the harm while posing negligible risk at worse.
Please Help CPSIA desperately needs to be amended to save vintage books and many other products valuable to children. We ask your help in supporting the many amendment bills. Specifically we’d like Congress to: • • • • Make the exemption for ordinary books permanent and retroactive. At a minimum, reduce the target age group from age 12 to age 18 months or 2 years (by which time nearly all children have stopped mouthing books) Stay implementation of the law until there has been time to evaluate products and procedures and rule on gray areas (like what is the cutoff for a collectible, which novelty books can be considered safe, the use of staples as bindings, etc.) Make it less scary to sell or distribute books: penalties are draconian for wellmeaning people trying to help children. Also, eliminate involvement of SAGs or at least require them to adhere to the CPSC’s guidelines and rulings. Say what you mean, and mean what you say. If there’s no intention/ability to prosecute small businesses or booksellers, don’t leave them under the umbrella of the law. Doing so unfairly puts law-abiding people in the position of breaking the law or abandoning their livelihood, while weakening the public’s confidence in the law and the necessity for it.
Protect Children from Lead in Meaningful, Proven Ways Instead of testing, certification, labeling of all products regardless of danger, let’s concentrate resources where they will do the most good: • improve nutrition (which reduces lead absorption); • provide support and training to parents (better supervised children have lower rates of poisoning); • continue to address clean-up of known significant hazards, like lead paint and lead in soil; • provide mental enrichment, especially for at-risk kids. Thank you.